Guzman v. Blanche
Split Score
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Case Summary
Disposition
Affirmed
The First Circuit denied Salvadoran petitioner Lesvi Lucia Monzon Guzman’s petition for review of a BIA order that had rejected her applications for asylum and withholding of removal. The court held that substantial evidence supported the agency’s finding that none of the harm she feared or suffered was ‘on account of’ a statutorily protected ground, so the nexus requirement for both asylum and withholding failed.
Circuit Split Identified
Legal Issue
Whether the ‘one central reason’ causation standard that governs asylum claims also applies to withholding-of-removal claims, or whether withholding requires only that a protected ground be ‘a reason’ for the feared persecution.
Circuit Positions
Withholding of removal requires the stricter ‘one central reason’ standard (same as asylum).
Withholding of removal is satisfied if a protected ground is merely ‘a reason’ (more lenient).
Issue unresolved / court declines to decide standard in this circuit.
Conflict Summary
Several circuits have held that an applicant seeking withholding of removal must show that a protected ground was ‘one central reason’ for the persecution (the same heightened standard that applies to asylum). Other circuits apply a more lenient test, requiring only that a protected ground be ‘a reason’—i.e., one of potentially several motives—for the persecution. In this opinion, the First Circuit expressly notes the divide but declines to choose a side.